PBMI 340B Forum Recap
PBMI’s second regional forum this year was in Atlanta and focused on the 340B landscape. Experts from the 340B industry provided a 360 view of this important healthcare program. The timing for this event could not be more relevant as it premiered on the heels of the 2018 outpatient prospective payment system (OPPS) ruling the day before.
Our presenters offered up specific feedback about the content for the day:
“Fully engaging on competing perspectives…”
“Great size. Good mix of experts.”
“It was great!”
Highlights from the six featured organizations are summarized below.
What is 340B and Why is it Important?
The Chief Compliance Officer of Pharmaceutical Strategies Group helped set the stage for the day by providing a comprehensive overview of 340B. Covered entities (CE) struggle just to keep their doors open. A successful 340B Program is tricky, but doable with the right help. To ensure that scarce resources go further, its incumbent upon CEs to have a 340B Program that is compliant. The speaker encouraged the audience, when possible, to work with external partners who knows 340B.
We were honored to have the Chief Executive Officer of Thrive Alabama as our keynote speaker. The speaker echoed how the 340B Program helped to stretch scarce resources for her organization. Because of their 340B Program, they were able to put $2.9M back into their organization specifically towards administration and patient care. “Compliance, compliance, compliance” was also emphasized “Don’t get ready for an audit, you should be ready all the time.” Among the thoughts keeping this Chief Executive Officer up at night were healthcare for low income Americans, stretching scarce federal dollars, and fixing healthcare. The 340B Program works for Thrive Alabama; without it they would exist, but with limited resources - 340B funding helps them to provide more.
What Are the Benefits of 340B and How is the Program Working for You?
Roundtable Discussion with Covered Entities
We were excited to hear from two organizational leaders (Program Manager of Froedtert Health and Assistant Director of Virginia Commonwealth University) who shared their insights into how their 340B Program is working for them. Both organizations have dedicated teams for their 340B Program and have a counsel in place. To help navigate around the complexities of healthcare, both panelists look to several sources for information (e.g., newsletters, discussions with internal departments and company entities, etc). GPO Prohibition, split billing, loss of $$ from Med Part C if not used, were among the challenges discussed. Having a contract pharmacy has been a benefit. Both panelists agree that the 340B Program is very valuable, and that losses would be significant if taken away.
Legal & Compliance Initiatives and 340B: Ensuring Effective Collaboration of Legal, Compliance, and Pharmacy Stakeholders
We also heard from a partner from Hall, Render, Killian, Heath & Lyman the nation's largest law firm focused exclusively on health care organizations. The speaker, who focuses on health law issues for health care providers across the country, helped the audience understand the future state of 340B, highlighted compliance risks for carve-in and challenges of carve out programs, and addressed the latest legal compliance updates since the recent passing of the OPPS ruling. Overall, patients will pay lower out of pocket costs, but hospitals will see a reduction in reimbursement.
Best Practices for Staffing a 340B Program
The Senior Vice President, Hospital and Health Systems Services from Visante, Inc. shared best practices for structuring a 340B Program and stressed the need to be audit ready. Having a cross-functional Compliance Steering Committee can help program managers and the pharmacy department make decisions around the program and address issues. Key takeaways:
340B Program integrity requires system level engagement
Program structure may vary based on program size and scope however, regardless of size all covered entities are expected to maintain program integrity
While messages were loud and clear that the 340B is complex, labor intensive, and compliance heavy, it was also clear that the program delivers great value to many healthcare organizations and the patients they serve.
Poviding an open forum, we accomplished our two goals for this meeting:
1) Took a deep dive into 340B
2) Provided an open forum for dialogue of varying stakeholders.
A special thank you to our speakers for educating us more on the 340B Program, sharing first-hand experiences, exploring best-practices and effective strategies, and helping us to understand the intricacy of legal compliance initiatives.